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REGIONALTRIALCOURT OF BATANGAS
FOURTH JUDICIAL REGION
BRANCH_____
BATANGAS CITY
REBECCA Z. BELO,
Plaintiff.
CIVIL CASE NO.____________
--versus-For Collection of Sum of Money
FRIDA Y. CALAYAN,
Defendant.
x------------------------------------------x
ANSWER
DEFENDANT, thru counsel, by way of answer to plaintiffs
complaint, to this Honorable Court respectfully states that:
Admissions/Denials
1. She ADMITS the allegations in paragraphs 2, 3 and 4 of the
Complaint;
2. She ADMITS the allegations in paragraph 5 only insofar as the oral
and written demands made by the plaintiff but DENIES the allegation
that she is unjustifiably and unreasonably refusing to deliver the laser
slimming machine subject of the contract, in fact, the laser slimming
machine was already packed and ready for delivery as early as
October 7, 2013 but plaintiff refused the delivery;
3. She ADMITS the allegations in paragraph 7 of the complaint;
4. She is without knowledge or information sufficient to form a belief as
to the truth of the allegations in paragraphs 6 and 8 of the complaint.
Page 1 of 5
end
model
and
costs
THREE
MILLION
PESOS
of
FIVE
HUNDRED
THOUSAND
PESOS
(Php500,000.00);
6. Plaintiff acted in bad faith in refusing to accept delivery of the
SUCTIOFAT-1000 laser slimming machine as agreed upon in the
contract and trying to force defendant to deliver a SUCTIOFAT-2000
laser slimming machine instead which would have caused losses on
the part of defendant;
7. Plaintiff acted in bad faith in refusing to annul the contract and to
accept the down payment which the defendant offered to return;
Counterclaim
Defendant additionally submits that he is entitled to relief arising from
the filing of this malicious and baseless suit, as follows:
8. Moral
damages
amounting
to
TWO
MILLION
PESOS
Page 2 of 5
Prayer
WHEREFORE, Defendant respectfully prays of this Honorable Court
that judgment be rendered ordering Plaintiff to comply with her obligations
as agreed upon in the contract or, in the alternative, to annul the contract and
accept the return of the down payment, and in any case, to order the Plaintiff
to pay the Defendant:
1. TWO MILLION PESOS (Php2,000,000.00) as moral damages;
2. TWO HUNDRED FIFTY THOUSAND PESOS (Php250,000.00) plus TWO
THOUSAND PESOS (Php2,000.00) for every hearing attended by
Defendants counsel as Attorneys fees;
3. The costs of this suit.
Other just and equitable reliefs are also prayed for.
Batangas City, 01 June 2015.
ESBATINP.RD
Counsel for Defendant
Attorneys Roll No.: 34768
IBP No.: 7625601/03/10
PTR No.: 9878201/03/03
MCLE Compliance No.: IV0001120
Page 3 of 5
Copy furnished:
CROIP.BLAN
Counsel for Plaintiff
123 Evangelista St.
Batangas City
EXPLANATION
Copy of the foregoing ANSWER was served to plaintiffs counsel by
registered mail due to time and distance constraints and for lack of the
undersigneds staff who can serve the same in person.
SEBASTIAN P. ARTADI
Page 4 of 5
ESBATINP.RD
Counsel for Defendant
Attorneys Roll No.: 34768
IBP No.: 7625601/03/10
PTR No.: 9878201/03/03
MCLE Compliance No.: IV0001120
Doc. No. 10
Page No. 50
Book No. V
Series of 2015
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